EnvironmentalProtection AgencyJohn R. Kasich, GovernorMary Taylor, It. GovernorScott J. Nally, Director

April 4, 2012

RE: ALCOA LANDFILLGROUND WATER MONITORINGNOTICE OF VIOLATION

CERTIFIED MAIL 7010 3090 0000 3936 7457

Mr. Richard King, Jr.Aluminum Company of America1600 Harvard AvenueCleveland, Ohio 44105

Dear Mr. King:

The Ohio Environmental Protection Agency (Ohio EPA) Northeast District Office (NEDO) Divisionof Materials and Waste Management (DMWM) received the "Semi-Annual Sampling and AnalysisReport, December 2011 Sampling Event and Assessment Monitoring Report." The documentwas dated January 31, 2012, and received by Ohio EPA on February 16, 2012. It was preparedfor ALCOA's Cleveland Works Landfill by Environmental Management and Consulting, Inc.(EM&C). The document was submitted in accordance with Ohio Administrative Code (OAC)Rules 3745-30-08(C) and (E) of the revised 2003 Residual and Industrial Solid Waste DisposalRegulations.

Upon review of the document, Ohio EPA finds that Alcoa is in violation of OAC Rule 3745-30-08(13)(3)(e) that states that all monitoring wells, included in the ground water monitoring programshall be designed, installed, and developed in a manner that allows the collection of ground watersamples that are representative of ground water quality in the geologic unit being monitored, and"[t]he monitoring wells, piezometers, and other measurement, sampling, and anal'ticaI devicesshall be operated and maintained to perform to design specifications throughout the life of theground water monitoring program."

Alcoa failed to maintain a ground water monitoring program that allows the collection of groundwater samples that are representative of ground water quality in the geologic unit beingmonitored. In particular, Ohio EPA noted that piezometer PZ-1 I has been damaged since 2004,and Ohio EPA has repeatedly recommended that the piezometer be properly abandoned.Furthermore, it now appears that piezometer PZ-7 is also damaged. To comply with this rule,piezometers PZ-7 and PZ-1 I and any other monitoring wells or piezometers that are damagedshould be properly abandoned and documented via abandonment reports.

Ohio EPA also noted that most of the volatile organic chemical concentrations are stable ordecreasing. However, monitoring well AL28 has increasing concentrations of vinyl chloride andcis-1,2-dichloroethene and monitoring well AL-21 which had its first detection of trans-1,2-dichloroethene (see table below).

Parameters UAS SZSunits ug/L MCL AL-21 AL-23S AL-24 AL-28

2 2.9vinyl chloride decreasing ND ND 5.4 increasing

Northeast District Office 330 1963 12002110 East Aurora Road 3301487 0769 (fax)Twinsburg, OH 44087-1924 www.epa.ohio.gov

Mr. Richard King, Jr.Aluminum Company of AmericaApril 4, 2012Page 2

1400 3.5 9.91,1-DCA OVAP ND decreasing decreasing 19 decreasing

200 1.61,1,1-TCA ND ND decreasing 0.41J decreasing

70 8.8 1.2cis-1 ,2-DCE increasing ND decreasing 5.2 increasing

100 0.24J 2.1trans-I ,2-DCE increasing ND ND stable

5 0.66J 0.80Jtrichioroethene ND ND decreasing decreasing

6100 0.69J 1.6chioroethane OVAP ND decreasing ND stable

Although ground water flow direction in the uppermost aquifer is generally west to west-southwesttoward the Cuyahoga River, Ohio EPA noted that the river gage indicates that river level is higherthan aquifer levels. This suggests a lag time in aquifer response to river level or the river gaugemay have moved. Therefore, Ohio EPA recommends that the river gauge be resurveyed on aregular basis to determine whether the reference point remains at the original elevation.

Nothing in this letter shall be construed to authorize any waiver from the requirements of anyapplicable state or federal laws or regulations. This letter shall not be interpreted to release theEntity from responsibility under Chapters 3704, 3714, 3734, or 6111 of the Ohio Revised Code orunder the Federal Clean Water or Comprehensive Environmental Response, Compensation, andLiability Acts for remedying conditions resulting from any release of contaminants to theenvironment.

If you have any technical questions regarding this review, please contact Kathryn Epp at (330)963-1233. Please submit all correspondence to Colum McKenna, Division of Materials andWaste Management, Northeast District Office, Ohio EPA, 2110 East Aurora Road, Twinsburg,Ohio 44087.

Sincerely,

6 i7Colum J.AcKennaEnvironmental SpecialistDivision of Materials and Waste Management

CJ Mid

cc: Kathryn Epp, DDAGW, NEDO Patrick Cook, TTSKelly Jeter, DMWM, CO Tom Anderson, EM&CMarty Cooper, LegalDane Tussel, Cuyahoga County Board of Health

File: [SOWERS/LAND/Alcoa LandfilliCOR/1 8] DMWM #4296